74 dismissal ordered by the SCJ was for acts that in its view constituted noncompliance with this provision of the law. 253. In other cases, inter-America jurisprudence and documents have established that norms of this type do not by themselves meet the requirements of strict legality; to the contrary, the breadth and imprecision of the language used allows for abuse as a means to silence ideas and opinions on matters of public interest. 254. In the case of Kimel v. Argentina, the Inter-American Court held that the laws criminalizing slander and libel violated Articles 13 and 9 of the American Convention, in relation to articles 1(1) and 2 thereof,313 because they were too broad and ambiguous. Later, when monitoring compliance with the judgment, the Court declared that the State had complied with the judgment when it amended the laws to add the element of intentionality to the description of the crimes and thereby narrowed the scope of application of a criminal law so as to protect speech that concerns matters of public interest and other matters.314 Likewise, in the case of Usón Ramírez v. Venezuela, the InterAmerican Court held that a law criminalizing slander, offense or disparagement of the Armed Forces of the Nation, in which the elements of the crime and the harm caused by the active subject were not clearly spelled out, allowed the aggrieved party’s subjectivity to determine whether a crime had been committed and thus violated articles 9 and 13 of the American Convention in relation to articles 1(1) and 2 thereof,315 because the law criminalizing the behavior was vague, ambiguous and imprecise.316 255. The IACHR understands that a judge has special obligations of discretion and prudence and, because of this, the need to protect the independence and impartiality of the judicial function may give rise to subsequent imposition of liability for abusive exercise of the right to freedom of expression. 313 The Court examined the language of Article 109, which provided that “[t]he false imputation of a publicly actionable crime resulting in a criminal proceeding shall be punished with imprisonment from one to three years” and Article 110, which provided that “[a]nyone who damages another person’s honor or reputation shall be punished with a fine from 1,500.00 to 90,000.00 pesos or imprisonment from one month to one year” and concluded that “taking into consideration the statements made by the State as to the inadequate criminal legislation regarding this matter, the Court deems that the pertinent criminal definition violates Articles 9 and 13(1) of the Convention, in relation to Articles 1(1) and 2 thereof. I/A Court H.R. Case of Kimel v. Argentina. Merits, Reparations and Costs. Judgment of May 2, 2008. Series C No. 177, paragraphs 64-67. 314 Cf. I/A Court H.R. Case of Kimel v. Argentina. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of May 18, 2010, paragraphs 30-35, Available at: www.corteidh.or.cr/docs/supervisiones/kimel_18_05_10.pdf; Cf. Law 26.551, enacted November 26, 2009, Available [in Spanish] at: http://infoleg.gov.ar/infolegInternet/anexos/160000-164999/160774/norma.htm. As amended, the respective articles of the Argentine Penal Code read as follows: Article 109: Slandering or falsely accusing a natural person of the commission of a specific offense under certain circumstances that make it a publicly actionable crime shall face punishment of three thousand ($3,000) to thirty thousand ($30,000) pesos. Remarks made concerning matters of public interest or not declaratory statements shall not be deemed slanderous. Article 110: Anyone who intentionally defames or discredits a natural person shall face a fine of fifteen hundred ($1,500) to twenty thousand ($20,000) pesos. In no case shall remarks impugning honor be deemed defamatory when they concern matters of public interest. 315 The then Article 505 of the Organic Code of Military Justice provided that: “Anyone who slanders, offends, or disparages the National Armed Forces or one of their entities shall face punishment of three to eight years in prison. Cf. I/A Court H.R. Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paragraphs 56-57. 316 Cf. I/A Court H.R. Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paragraphs 56-57.